Expired Commission and the Wrong Data Report Form
A repair organization completes a repair on a 500-gallon, 200 psig air receiver and submits an R-1 data report to the National Board for registration. The National Board returns the report because the Authorized Inspector's commission number shown on the form expired 10 days before the inspection date, and because the work included adding a 20 in. manway that required a reinforcement calculation, which the AI treated as a repair. The shop's QA manager asks the AIS to 'fix the dates' and resubmit the same R-1 so the customer can close out the project. The AI's commission renewal application was pending but not issued at the time of inspection. The jurisdiction has adopted the NBIC 2023 edition and requires registration before the vessel is returned to service. The AIS must decide whether the inspection can be ratified, what form is required, and how to correct the registration without creating a false record.
1. Can the AIS backdate the inspection or ratify the expired-commission inspection?
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No. The AI must hold a valid National Board commission on the date of inspection and on the date of signature. A pending renewal is not a commission. Backdating the inspection or the signature is falsification of a data report and is not a records correction. The repair must be inspected by an AI whose commission was valid at the time, or re-inspected after the renewal is issued, with jurisdiction acceptance. The AIS should notify the agency and the jurisdiction, withdraw the defective R-1, and document the sequence. If the work is still accessible, re-inspection is the cleanest cure; if not, the jurisdiction may require additional nondestructive examination or other verification. The AIS should not let the customer's schedule dictate a false record, because the registration would remain traceable and the false date could be detected later.
2. Was adding the 20 in. manway a repair or an alteration, and which data report is required?
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Adding a 20 in. manway is an alteration, not a repair. It changes the vessel configuration, requires a reinforcement calculation, and may require supplemental marking. An R-1 for a repair is the wrong record. The repair organization needs design calculations, AI review, and the alteration data report required by NBIC Part 3, plus any jurisdiction permit. The AI should not sign an R-1 that describes the work as a repair. If the manway was already installed, the alteration still needs to be documented and reviewed; the form cannot be chosen to fit the filing. The AIS should also verify that the reinforcement calculation was reviewed by the AI before the manway was welded, or document why a retrospective review is technically acceptable and what additional examination is needed.
3. What steps should the AIS take to correct the registration and prevent recurrence?
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Correct the record; do not 'fix' it. Withdraw the rejected R-1, prepare the correct alteration report with the proper edition and a valid AI signature, attach the calculations and nondestructive examination records, pay the required fees, and resubmit. Notify the jurisdiction that the vessel was returned to service only after the corrected registration, or obtain the jurisdiction's written approval for the sequence. The National Board registration is an administrative record, not an approval of the alteration; the agency's review and the jurisdiction's acceptance are separate. The AIS should add a pre-submittal checklist covering commission dates, form selection, code edition, signatures, and attachments. The AIS should also review why the AI treated an alteration as a repair and provide training or counseling, because the error is technical, not merely clerical.